Jerry and Patricia A. Dixon, et al - Page 234




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            the Court indicating no objection to the lifting of the                                        
            protective orders.                                                                             
            Section 7458, which governs hearings before the Tax Court,                                     
            provides that such hearings shall be open to the public.  In                                   
            addition, section 7461, entitled "Publicity of Proceedings",                                   
            provides in pertinent part:                                                                    
                  SEC. 7461(a). General Rule.--Except as provided in                                       
                  subsection (b), all reports of the Tax Court and all                                     
                  evidence received by the Tax Court and its divisions,                                    
                  including a transcript of the stenographic report of                                     
                  the hearings, shall be public records open to the                                        
                  inspection of the public.                                                                
                  (b) Exceptions.--                                                                        
                  (1) Trade Secrets or Other Confidential                                                  
                  Information.--The Tax Court may make any provision                                       
                  which is necessary to prevent the disclosure of trade                                    
                  secrets or other confidential information, including a                                   
                  provision that any document or information be placed                                     
                  under seal to be opened only as directed by the court.                                   
            Rule 103 provides that upon motion by a party or other                                         
            affected person, and upon good cause shown, the Court may make                                 
            any order which justice requires to protect a party or other                                   
            person from annoyance, embarrassment, oppression, or undue burden                              
            or expense.                                                                                    
                  Sections 7458 and 7461 reflect the well-established                                      
            principle that official proceedings and records of all courts,                                 
            including the Tax Court, generally shall be open and available to                              
            the public.  See Nixon v. Warner Communications, Inc., 435 U.S.                                
            589, 597 (1978); Willie Nelson Music Co. v. Commissioner, 85 T.C.                              
            914, 917 (1985).  However, section 7461 and Rule 103 provide that                              
            the Court has the discretionary authority to order all or part of                              

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